From: Brad Bartells [bbartells@redcent.com]
Sent: Thursday, April 25, 2002 2:50 PM
To: rule-comments@sec.gov
Subject: File No. S7-08-02
From: Bradley J. Bartells
Regarding the SEC's proposed rule changes for accelerating the filing period
for quarterly and year-end information:
To sum it up - this is a bad idea! This proposed rule change will have the
opposite effect of what the SEC is trying to achieve. Reducing the filing
period for forms 10-Q and 10-K will only cause the financial information to
be less reliable. By reducing the filing period, publicly held companies
and their CPA's will feel rushed to complete their year-end audits and
quarterly filings. This will only cause more errors to be made, or
overlooked and not corrected.
It appears that the SEC is attempting to make the financial data more
reliable for investors. This proposal will have the opposite effect. A
company that has inaccurate financial data on March 31 is going to have the
same inaccurate data on March 1. Reducing the filing period will not
somehow magically transform the financial data into accurate numbers, it
will only reduce the time it takes to release the inaccurate data to
investors.
If the intentions of the SEC are to have more accurate financial data
available to investors and the public, I suggest that the SEC work with the
AICPA and FASB to come up with ways to make outside auditors 1) more
responsible for the financial statements that they audit and 2) create
restrictions on non-audit services provided by CPA firms. These non-audit
services create independence issues for the audit firms.
I hope the SEC reconsiders its proposed reduction in filing periods for
forms 10-Q and 10-K , and it can see that this proposal is not going to
accomplish what the SEC is trying to accomplish.
Bradley J. Bartells, CPA
Senior Accountant/Finance
Centennial First Financial Services
Redlands Centennial Bank
909-798-3611
bbartells@redcent.com
www.redcent.com